Corrective Action Plans

Finding 46372 (2022-035)

Significant Deficiency 2022

WV

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

SPECIAL TESTS AND PROVISIONS ? UTILIZATION CONTROL AND PROGRAM INTEGRITY Department of Health and Human Resources (DHHR) Assistance Listing Number 93.775, 93.777, COVID-19 93.777, 93.778, ARRA ? 93.778 The DHHR Bureau for Medical Services plans to leverage existing case closure policies and procedu...

SPECIAL TESTS AND PROVISIONS ? UTILIZATION CONTROL AND PROGRAM INTEGRITY Department of Health and Human Resources (DHHR) Assistance Listing Number 93.775, 93.777, COVID-19 93.777, 93.778, ARRA ? 93.778 The DHHR Bureau for Medical Services plans to leverage existing case closure policies and procedures and implement an updated case tracking system which, through workflow rules, will make the closure process and requirements explicit so the system will not permit closures without record of all required information and manager approval. This new system is being implemented as part of an ongoing data warehouse project and should be in place by April 1, 2023.

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Finding 46362 (2022-026)

Material Weakness 2022

State of West Virginia

WV

Matching / Level of Effort / Earmarking § 200.303

INTERNAL CONTROLS OVER CHILD CARE PROVIDER ELIGIBILITY FOR ARP ACT STABILIZATION FUNDS Department of Health and Human Resources (DHHR) Assistance Listing Number 93.489, 93.575, 93.596, COVID-19 93.575 The DHHR Bureau for Family Assistance, Division of Early Care and Education, has a process in pl...

INTERNAL CONTROLS OVER CHILD CARE PROVIDER ELIGIBILITY FOR ARP ACT STABILIZATION FUNDS Department of Health and Human Resources (DHHR) Assistance Listing Number 93.489, 93.575, 93.596, COVID-19 93.575 The DHHR Bureau for Family Assistance, Division of Early Care and Education, has a process in place for the approval of ARP stabilization funding for childcare providers set forth in the West Virginia Child Care Stabilization Payment Policy and Procedure Manual that includes: ? Eligibility of childcare providers (Chapter 2: Overview of WV Child Care Stabilization Payment Eligibility, Section 2.1), ? Conditions under which childcare providers are eligible (Chapter 2: Overview of WV Child Care Stabilization Payment Eligibility, Section 2.2), ? Ineligible childcare providers (Chapter 2: Overview of WV Child Care Stabilization Payment Eligibility, Section 2.3) ? An application process for childcare providers to apply for ARP stabilization funding (Chapter 5: Application Process, Sections 5.0, 5.1 and 5.2). Beginning in August 2022, the Division of Early Care and Education began auditing childcare providers (in batches of 300) to ensure appropriate use of the funds by requesting invoices and statements showing how the provider has utilized the ARP funding they have been awarded. Each quarter, a new batch is being audited until all childcare providers participating in the ARP stabilization funding have been audited. The procedure manual referenced above explains that the documentation relevant to providers? applications, eligibility, and audit findings are maintained within each provider?s FACTS provider case record. The Division?s tracking of providers deemed to be ?in good standing? is maintained within a manually updated tracking form housed on the Division?s internal server. By May 1, 2023, the Division of Early Care and Education will modify the West Virginia Child Care Stabilization Policy and Procedure Manual to document workflows more clearly for the award and monitoring of stabilization grants, as well as how the Division will more effectively produce such documentation to ensure that controls are operating effectively.

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Finding 46359 (2022-040)

Significant Deficiency 2022

State of West Virginia

WV

Reporting § 200.303

SCHEDULE OF EXPEDNITURES OF FEDERAL AWARDS Division of Corrections and Rehabilitation (DCR) Assistance Listing Number 93.788 The Division of Administrative Services provides fiscal oversight for the DCR. While reporting for the Opioid STR grant, the expenditures were calculated incorrectly and in...

SCHEDULE OF EXPEDNITURES OF FEDERAL AWARDS Division of Corrections and Rehabilitation (DCR) Assistance Listing Number 93.788 The Division of Administrative Services provides fiscal oversight for the DCR. While reporting for the Opioid STR grant, the expenditures were calculated incorrectly and included transactions outside of the current fiscal year. Policies and procedures have been updated effective January 2023 to ensure the SEFA is reported accurately using the correct parameters on the reports.

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Finding 46358 (2022-039)

Material Weakness 2022

State of West Virginia

WV

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.303

TRANSPARENCY ACT REPORTING Department of Health and Human Resources (DHHR) Assistance Listing Number 93.788 For the one report that had an incorrect subaward amount, the subrecipient?s DUNS number was mistakenly keyed into the FSRS system as the subaward amount. For the one report that was not sub...

TRANSPARENCY ACT REPORTING Department of Health and Human Resources (DHHR) Assistance Listing Number 93.788 For the one report that had an incorrect subaward amount, the subrecipient?s DUNS number was mistakenly keyed into the FSRS system as the subaward amount. For the one report that was not submitted timely, the DHHR awarded the grant to the subrecipient on December 5, 2021. The amount of the subaward was $220,000. The identifying information for the subaward was submitted to FSRS.gov on January 30, 2022, which was timely. On June 2, 2022, the DHHR approved a change order to the subaward, which increased the amount of the subaward to $502,131. Accordingly, the FSRS report was reopened on July 29, 2022, whereby the subaward amount was increased to $502,131. However, the report was not actually submitted within the FSRS system until November 8, 2022. Both of these instances were due to human error and were passed on to the appropriate offices within the DHHR. The staff member in charge of the FFATA reporting for the DHHR was made aware of the instances in an effort to improve controls and has corrected the reports in FSRS.

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Finding 46357 (2022-038)

Material Weakness 2022

State of West Virginia

WV

Questioned Costs Cash Management § 200.303 § 200.305

SUBRECIPIENT CASH MANAGEMENT Department of Health and Human Resources (DHHR) Assistance Listing Number 93.788 The DHHR Bureau for Behavioral Health concurs with the recommendation to mandate additional documentation to support amounts of drawdowns that appear to exceed a subrecipient's immediate ...

SUBRECIPIENT CASH MANAGEMENT Department of Health and Human Resources (DHHR) Assistance Listing Number 93.788 The DHHR Bureau for Behavioral Health concurs with the recommendation to mandate additional documentation to support amounts of drawdowns that appear to exceed a subrecipient's immediate cash needs. Upon identification of the condition that led to this finding, the bureau provided additional guidance to all internal grant staff. The guidance was distributed on October 25, 2022 and requires a documented justification for approval of any invoice that appears to exceed 10% of total grant amount for cash on hand. The bureau also intends to seek out and provide technical assistance and/or training for internal staff and subrecipients to ensure they understand the cash management requirements within 2 CFR 200.305.

View Audit 40967 Questioned Costs: $1

Finding 46356 (2022-034)

None 2022

State of West Virginia

WV

Questioned Costs Eligibility

ELIGIBILITY Department of Health and Human Resources (DHHR) Assistance Listing Number 93.767 For the one instance ?where the social security number, age, date of birth, and immigration status was not verified in the Data Exchange System,? the DHHR Bureau for Family Assistance has requested the cre...

ELIGIBILITY Department of Health and Human Resources (DHHR) Assistance Listing Number 93.767 For the one instance ?where the social security number, age, date of birth, and immigration status was not verified in the Data Exchange System,? the DHHR Bureau for Family Assistance has requested the creation of an administrative report to identify cases without a social security number entered in applicable case records. This report will be available by February 28, 2023 and will eventually be generated on a quarterly basis. For the nine instances ?where income was not verified,? the DHHR Bureau for Family Assistance will develop additional training that is targeted at both the verification of income and non-financial factors such as date of birth, age, and social security numbers. The training materials will be available to field staff by March 31, 2023 and will include a mandatory completion date of April 30, 2023.

View Audit 40967 Questioned Costs: $1

Finding 46355 (2022-033)

Material Weakness 2022

State of West Virginia

WV

Special Tests & Provisions Reporting Matching / Level of Effort / Earmarking § 200.303

SPECIAL TESTS AND PROVISIONS ? MANAGED CARE FINANCIAL AUDIT Department of Health and Human Resources (DHHR) Assistance Listing Number 93.767 Starting July 1, 2023, WV CHIP will be included in the Medicaid managed care contracts and will be consolidated into Medicaid's oversight and monitoring proce...

SPECIAL TESTS AND PROVISIONS ? MANAGED CARE FINANCIAL AUDIT Department of Health and Human Resources (DHHR) Assistance Listing Number 93.767 Starting July 1, 2023, WV CHIP will be included in the Medicaid managed care contracts and will be consolidated into Medicaid's oversight and monitoring processes. This consolidation will ensure that audited financial reports are submitted by the managed care organizations and documentation of review and approval is maintained.

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Finding 46354 (2022-032)

None 2022

State of West Virginia

WV

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.1 § 200.302 § 200.403 § 200.456

ALLOWABILITY OF EXPENDITURES Department of Health and Human Resources (DHHR) Assistance Listing Number 93.767 Microdyn OPPS quarterly updates for Pricer and Editor Dynamic Link Libraries (DLLs) are commonly received mid-month of the first month in the quarter after the Centers for Medicare and Med...

ALLOWABILITY OF EXPENDITURES Department of Health and Human Resources (DHHR) Assistance Listing Number 93.767 Microdyn OPPS quarterly updates for Pricer and Editor Dynamic Link Libraries (DLLs) are commonly received mid-month of the first month in the quarter after the Centers for Medicare and Medicaid Services releases quarterly updates. During 2022, releases occurred on January 15, April 16, July 16, and October 19. Although updates to the DLL were completed timely throughout the year, claims sampled for the audit fell into the periods of delay between the first day of the quarter and the updates to the DLL. Procedures are in place to reprocess any affected claims once the quarterly updates have been uploaded into the system. However, there was an interruption in the procedure to reprocess claims after the quarterly updates were uploaded to the claims processing system. Corrective action has already been implemented that includes automatically opting and populating the "reprocess claims" flag in the Request Management System (RQMS) when the Microdyn OPPS updates are entered to work. (The RQMS is the system used to enter and manage work orders for the Medicaid Management Information System.) Claims processing staff at the fiscal agent have also entered calendar reminders to reprocess claims as necessary after the OPPS quarterly updates are processed. All affected claims including claims sampled for the Single Audit were reprocessed and paid from mid-December 2022 through mid-January 2023.

View Audit 40967 Questioned Costs: $1

Finding 46353 (2022-031)

Material Weakness 2022

State of West Virginia

WV

Special Tests & Provisions Reporting Matching / Level of Effort / Earmarking § 200.303

SPECIAL TESTS AND PROVISIONS ? MEDICAL LOSS RATIO (MLR) Department of Health and Human Resources (DHHR) Assistance Listing Number 93.767, 93.775, 93.777, COVID-19 93.777, 93.778, ARRA 93.778 Starting July 1, 2023, WVCHIP will be included in the Medicaid managed care contracts and will be consolida...

SPECIAL TESTS AND PROVISIONS ? MEDICAL LOSS RATIO (MLR) Department of Health and Human Resources (DHHR) Assistance Listing Number 93.767, 93.775, 93.777, COVID-19 93.777, 93.778, ARRA 93.778 Starting July 1, 2023, WVCHIP will be included in the Medicaid managed care contracts and will be consolidated into Medicaid's oversight and monitoring processes. This consolidation will ensure that documentation of review and approval of MLR reporting is maintained.

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Finding 46352 (2022-030)

Material Weakness 2022

State of West Virginia

WV

Eligibility Special Tests & Provisions Matching / Level of Effort / Earmarking § 200.303

SPECIAL TESTS AND PROVISIONS ? PROVIDER ELIGIBILITY Department of Health and Human Resources (DHHR) Assistance Listing Number 93.767 For the population related to provider eligibility, the auditors were provided a population/report of active providers, which the auditors used to select their sampl...

SPECIAL TESTS AND PROVISIONS ? PROVIDER ELIGIBILITY Department of Health and Human Resources (DHHR) Assistance Listing Number 93.767 For the population related to provider eligibility, the auditors were provided a population/report of active providers, which the auditors used to select their sample. To determine if a provider is enrolled or terminated, the provider record must be accessed, and the enrollment effective date and termination effective date must be viewed. The termination dates on the provider record are accurate in HPAS (claims processing/payments system), as the claims processing system refers to the dates on the provider record. However, radio buttons in HPAS, system do not accurately reflect active enrollment. Claims submitted by terminated providers (providers with no active enrollment) are denied. The processing system looks for a termination date on the provider record and denies claims for providers with termination dates. No payments were made to providers with terminated enrollment and no claims payment errors were identified. Two other errors identified resulted from human error. One provider was erroneously indicated as enrolled with CHIP but had no CHIP contract attached in the system, and one provider did not receive an approval letter. Continuing training will be conducted with provider enrollment staff to ensure plan relationships are removed if not applicable and that letters are manually generated when the application is also manually reviewed.

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Finding 46335 (2022-029)

Material Weakness 2022

State of West Virginia

WV

Subrecipient Monitoring Reporting § 200.303

TRANSPARENCY ACT REPORTING Department of Health and Human Resources (DHHR) Assistance Listing Number 93.558, COVID-19 93.558, 93.568, COVID-19 93.568 The Office of Grants Management, Division of Grant Administration and Reporting, is responsible for submitting the FFATA reports for the DHHR. The FF...

TRANSPARENCY ACT REPORTING Department of Health and Human Resources (DHHR) Assistance Listing Number 93.558, COVID-19 93.558, 93.568, COVID-19 93.568 The Office of Grants Management, Division of Grant Administration and Reporting, is responsible for submitting the FFATA reports for the DHHR. The FFATA reports are available for all newly issued subawards and change orders throughout the DHHR each month. The source for these FFATA reports is the DHHR's subrecipient Grants Management Solution system (CRM) and an interface with the state accounting system (wvOASIS). Grants Management reviews each federal Notice of Grant Award to determine if reporting is required. Notes are input on the FFATA reports for each subaward as to whether that subaward is being reported or not. Grants Management then uploads and reviews the required data elements onto FSRS.gov before the reports are electronically submitted. For prior DHHR grant awards (e.g., fiscal year 2021), even if the DHHR passed through a portion of the award to other components of the State of West Virginia (i.e., other non-federal entities that are governmental agencies of the state but are external to the DHHR), the DHHR considered those other governmental agencies to be subrecipients of the DHHR instead of being part of the state's prime recipient tier. This viewpoint proved to be incorrect because transfers of federal awards to another component of the same auditee under 2 CFR 200, Subpart F, do not constitute a subrecipient or contractor relationship; furthermore, a grant agreement is the only means by which the DHHR can pass through a portion of the federal award to state agencies that are external to the DHHR. During fiscal year 2022, the DHHR revised its practice when awarding funds to agencies of the state that are external to the DHHR. The DHHR began considering those other governmental agencies to be part of the state?s prime recipient tier instead of being first tier subrecipients of the DHHR. Accordingly, when transferring federal awards to another state agency, the DHHR Office of Grants Management and DHHR Spending Units started working together as necessary to ensure that all subawardee information for the state is complete and accurate. During fiscal year 2022, the DHHR also revisited its standard grant agreement template in relation to other state agencies. Although changes to the main body of the grant agreement were not necessary, the DHHR made a revision to Exhibit G (?Required Reports?) of the agreement. When a ?grant? was provided to another state agency using federal funds as the source of the grant, in whole or in part, the Office of Grants Management instructed the spending unit to review the detailed line-item budget and conduct other pre-award procedures as may be necessary (e.g., inquiring of the other state agency) to determine if the other state agency planned to subgrant a portion of the funds. If the other state agency planned to subgrant a portion of the funds, the Office of Grants Management required the spending unit to include a clause within Exhibit G of the grant agreement that required the other state agency to provide the FFATA data to the spending unit on a monthly basis (due 15 days after the end of each month). Upon receiving the FFATA data from the other state agency, the spending unit was then required to submit the information to the DHHR Office of Grants Management for purposes of timely FFATA reporting to FSRS.gov. Prior to October 5, 2022, this process was accomplished via informal discussions (e.g., emails to and from other state agencies, monitoring calls, meetings held between the Office of Grants Management and spending units on a regular basis, etc.). Effective October 5, 2022, the DHHR formalized this process via a system directive from DHHR Finance to all users of the DHHR's subrecipient Grants Management Solution system (CRM). These additional controls should resolve the condition that led to the LIHEAP portion of the finding. For the TANF portion, the Context section of the finding references subawards from the West Virginia Department of Education (DOE). As additional context, when issuing their subawards, it should be noted that the DOE utilized TANF monies that it had received from the DHHR. When passing through the money to the DOE, the DHHR utilized a grant agreement since such an agreement is the only means by which the DHHR could pass through a portion of the award to another state agency. During fieldwork for the West Virginia Single Audit, the DOE informed the State?s independent auditors that the DOE subgranted a portion of the TANF funds to five different subrecipients; the State?s independent auditors then informed the DHHR. This was unbeknownst to the DHHR at the time. From a general regulatory perspective, the DHHR grant agreement required the DOE to obtain prior written approval from the DHHR before entering into any subgrant agreements with the funds. From a budgetary perspective, the DOE was required to contact the DHHR spending unit for prior approval and specific instructions regarding the subgranting of DHHR awards; provide the names of each organization that would receive subgrants, when known; and provide an overall narrative stating the purpose of each subgrant. From the FFATA perspective, the DHHR spending unit was required to utilize the DOE?s budgetary narrative, add a related reporting requirement within Exhibit G of the grant agreement, and utilize the resulting disclosures when submitting data to the DHHR Office of Grants Management for purposes of accurate FFATA reporting to FSRS.gov. The breakdown in controls happened because the DOE did not obtain prior written approval from the DHHR spending unit prior to entering into the subgrant agreements and did not indicate any subgrant expenditures within their quarterly financial reports and reconciliations of payments received and actual expenditures incurred, all of which are required per the terms and conditions of the DHHR grant. To enhance the controls, the DHHR spending unit will increase the level of risk associated with the DOE and will impose additional award conditions upon the DOE, such as requiring the DOE to submit certifications or written representations regarding subawards in the future, as are authorized per 2 CFR 200.209 (?Certifications and representations?).

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Finding 46334 (2022-028)

Material Weakness 2022

State of West Virginia

WV

Special Tests & Provisions Eligibility Matching / Level of Effort / Earmarking § 200.303

SPECIAL TESTS AND PROVISIONS ? INCOME ELIGIBILITY AND VERIFICATION SYSTEM Department of Health and Human Resources (DHHR) Assistance Listing Number 93.558, COVID-19 93.558 The Income and Eligibility Verification System (IEVS) provides the DHHR Bureau for Family Assistance (the Bureau) with sources...

SPECIAL TESTS AND PROVISIONS ? INCOME ELIGIBILITY AND VERIFICATION SYSTEM Department of Health and Human Resources (DHHR) Assistance Listing Number 93.558, COVID-19 93.558 The Income and Eligibility Verification System (IEVS) provides the DHHR Bureau for Family Assistance (the Bureau) with sources of information for use in determining eligibility and the amount of the benefit for applicants and recipients. Procedures established to assist in the prevention of fraud and abuse in the form of computer matches are utilized. The social security number of the applicant or recipient is matched against the files from the West Virginia Bureau of Employment Programs, the Internal Revenue Service, and the Social Security Administration (SSA). The State Online Query (SOLQ) provides direct access to SSA?s databases. Information received includes SSN verification; Supplemental Security Income (SSI); and Retirement, Survivors, and Disability Insurance (RSDI) details. Requests can be made only for individuals known to the eligibility system within the previous five years. The Bureau?s Policy Unit will collaborate with the Bureau?s Division of Professional Development to create a more detailed and precise training for the IEVS System. The blackboard platform will allow supervisors to track workers that have completed the training. The anticipated date for completion is June 30, 2023. Furthermore, the Policy Unit will send out various IEVS Policy Reminders and will work to revise the IEVS User Guide.

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Finding 46333 (2022-027)

Material Weakness 2022

State of West Virginia

WV

Special Tests & Provisions Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

INTERNAL CONTROLS OVER SPECIAL TESTS AND PROVISIONS ? CHILD SUPPORT NON-COOPERATION, PENALTY FOR REFUSAL TO WORK, AND ADULT CUSTODIAL PARENT OF CHILD UNDER SIX WHEN CHILD CARE NOT AVAILABLE Department of Health and Human Resources (DHHR) Assistance Listing Number 93.558, COVID-19 93.558 The WV WOR...

INTERNAL CONTROLS OVER SPECIAL TESTS AND PROVISIONS ? CHILD SUPPORT NON-COOPERATION, PENALTY FOR REFUSAL TO WORK, AND ADULT CUSTODIAL PARENT OF CHILD UNDER SIX WHEN CHILD CARE NOT AVAILABLE Department of Health and Human Resources (DHHR) Assistance Listing Number 93.558, COVID-19 93.558 The WV WORKS Policy Unit within the DHHR Bureau for Family Assistance will continue to send out reminders and Sanction Flowchart/Desk Guides to staff. The bureau?s Policy Unit will work with the bureau?s Division of Professional Development regarding the continued use of Blackboard Courses and Virtual Training. The WV WORKS Council will add a ?Sanction Workshop? to Payment Accuracy Conferences; the anticipated date for completion is August 31, 2023. Finally, the Policy Unit will continue to review RAPIDS Management Reports monthly regarding third level sanctions to ensure the sanctions are being sent to the Policy Unit for review and approval.

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Finding 46314 (2022-041)

Material Weakness 2022

State of West Virginia

WV

Subrecipient Monitoring § 200.303

INTERNAL CONTROLS OVER SUBRECIPIENT MONITORING Department of Health and Human Resources (DHHR) Assistance Listing Number 93.788, 93.575, COVID-19 93.575, 93.596, 93.558, COVID-19 93.558, 93.323, COVID-19 93.323 In an effort to enhance the manner by which it documents the assessment of risk, DHHR Fi...

INTERNAL CONTROLS OVER SUBRECIPIENT MONITORING Department of Health and Human Resources (DHHR) Assistance Listing Number 93.788, 93.575, COVID-19 93.575, 93.596, 93.558, COVID-19 93.558, 93.323, COVID-19 93.323 In an effort to enhance the manner by which it documents the assessment of risk, DHHR Finance has developed a Risk Assessment Form and Certification for the Award and Monitoring of Grants. Prior to submitting a draft grant agreement to DHHR Finance for processing, the spending unit will be required to complete the risk assessment form, affix any supporting documentation if desired or deemed necessary for proper disclosure, and upload a copy of the package to the Document Manager section of DHHR's subrecipient Grants Management Solution system (CRM). As part of their review of the draft grant agreement, the Office of Grants Management will check the Document Manager section of CRM to ensure the form is uploaded, completed in full, and signed by the Spending Unit. If the form is not in the Document Manager section of CRM or is incomplete, the Office of Grants Management will return the grant agreement to the Spending Unit via the standard workflow process. To ensure these additional controls surrounding Grantee evaluations and monitoring are working as intended, the Office of Internal Control and Policy Development will select a sample of forms to review on an intermittent basis; discuss the forms, the process for completing the forms, and the backup documentation with the Spending Unit if deemed necessary; and report the results to the DHHR Chief Financial Officer for further action or instructions. The risk assessment form and process are currently in draft form and under internal review. If approved, the form and process will be effective for all grant awards with a start date beginning on or after July 1, 2023. To enhance the manner by which the DHHR documents the level of monitoring during various stages of the grant, the DHHR still plans to break out the mandatory monitoring checklist (i.e., the certifications required within the checklist) into multiple parts, which will include documenting subrecipient risk and the monitoring activities that are performed throughout the life cycle of the grant. Although the formal corrective action plan in the prior year indicated that the estimated date for completion was September 30, 2022, the estimated date for completion at this stage is July 1, 2023.

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Finding 46292 (2022-024)

Significant Deficiency 2022

State of West Virginia

WV

Cash Management § 200.303

CASH MANAGEMENT Southern West Virginia Community and Technical College, West Virginia Northern Community and Technical College, and Mountwest Community and Technical College Assistance Listing Number 84.425E, 84.425F, 84.425J, 84.425M Southern West Virginia Community and Technical College (SWVCC) r...

CASH MANAGEMENT Southern West Virginia Community and Technical College, West Virginia Northern Community and Technical College, and Mountwest Community and Technical College Assistance Listing Number 84.425E, 84.425F, 84.425J, 84.425M Southern West Virginia Community and Technical College (SWVCC) response SWVCC has implemented new procedures for drawdowns of federal funds. Federal grants are done on a reimbursement basis. Due to the unpredictability of when invoices may be processed at the State level, SWVCC will ?front? the expenses from State funds moving forward. Separate accounts have been set up in our accounting system for this purpose. Once invoices have been paid and posted to the wvOasis accounting system, SWVCC will run periodic reports to request reimbursement of grant eligible expenses. Documentation will be completed demonstrating the exact expenses (transactions) being requested for reimbursement and the expenses will be reviewed before a drawdown is approved. This documentation will be maintained for audit review. These procedures are in place as of January 2023. West Virginia Northern Community and Technical College (WVNCC) response WVNCC has added a layer of control by transferring the task of federal fund drawdowns from the Comptroller to the Accountant Senior to the Comptroller and CFO. In addition, WVNCC has transferred the task of reconciling federal funds from the Accountant Senior to the Comptroller. This action was implemented in January 2023. Mountwest Community and Technical College (MCTC) response Effective February 2022, policies and procedures were implemented to ensure drawdown requests were made through the issuance of G5 drawdown forms. For the one instance where approval signature occurred after the draw of funds, approval was obtained via email. Policies and procedures were enhanced to ensure approvals occur before drawdown from the CFO for transactions and are documented.

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Finding 46291 (2022-023)

Material Weakness 2022

State of West Virginia

WV

Questioned Costs Equipment & Real Property Management Matching / Level of Effort / Earmarking § 200.303

ALLOWABILITY Bluefield State University, Glenville State University, and Mountwest Community and Technical College Assistance Listing Number 84.425E, 84.425F, 84.425J, 84.425M Bluefield State University (BSU) response P425F200727 $19,882?BSU agrees with the finding that these were routine maintena...

ALLOWABILITY Bluefield State University, Glenville State University, and Mountwest Community and Technical College Assistance Listing Number 84.425E, 84.425F, 84.425J, 84.425M Bluefield State University (BSU) response P425F200727 $19,882?BSU agrees with the finding that these were routine maintenance costs that, which would mitigate the spread of COVID, would have been incurred by the University in any event. BSU has put in place procedures to review all future use of funds to be certain that are specifically related to COVID mitigation. P425J200063?BSU believes the questioned costs in this finding were allowable. At the time BSU made the draw for the costs, BSU based the decision on FAQ #23 and used the definition of minor remodeling. This wall is within a previously completed functioning building, and does not structurally alter the building, therefore, BSU deemed it to be remodeling. Due to the overall cost of the wall in comparison to the market value of the building BSU deemed it to be minor. As stated in 34 CFR ? 77.1, ?[m]inor remodeling means minor alterations in a previously completed building? and also includes the extension of utility lines, such as water and electricity, from points beyond the confines of the space in which the minor remodeling is undertaken but within the confines of the previously completed building.? The response to Question #24 of the FAQ provides some additional guidance and specific examples of permissible ?minor remodeling? that may be paid for with HEERF grant funds. The remodeling in this case was very similar to the examples of permissible minor remodeling provided in the FAQ. Obtaining the hospital building permitted BSU to offer on-campus housing in a portion of the hospital that was converted into student dormitories. Another part of the building remained in use as a hospital. HEERF funds were used to construct a wall between the dormitory area and the part of the building being used as an Emergency Room. As a result, the construction of the wall in question was ?for purposes associated with the coronavirus? and should be viewed as an eligible HEERF expenditure. The related plumbing and electrical work should also be viewed as a permissible expenditure given the reference in the response to FAQ #24 to ?the extension of utility lines, such as water and electricity, from points beyond the confines of the space in which the minor remodeling is undertaken but within the confines of the previously completed building.? As indicated previously, at the time the decision to use HEERF fund for the construction of the wall, prior approval was not required. The project in question can be fairly characterized as a minor alteration in a previously completed building for the purposes of preventing the spread of COVID-19. For all of the reasons discussed above, BSU respectfully maintains that the construction of the wall in question and the related electrical and plumbing work should be viewed as an eligible expenditure. P425E200618: BSU believes awards were made in good faith and according to the regulations, as described below. However, BSU proposes the following corrective action plan to mitigate the issue. BSU used $305,191 of institutional funds to make emergency grants to students that the auditors agree meet the definition in the FAQs. These grants were based solely on the number of credits the students were enrolled in during the term or were to pay for books for students who requested assistance. BSU proposes to reimburse the Institutional funds for those grants from the above amount drawn. That would leave a balance of $1,291,079 in dispute and free up those Institutional funds for upcoming COVID related expenses. Additionally, BSU has HBCU funds that are unspent as of the date of this response. BSU proposes to reimburse the remaining balance of $1,291,079 from the HBCU funds. BSU believes these are valid expenses for HBCU funds. That would return those funds to the Student portion, which would allow BSU to make additional emergency payments to students before the funds expire on June 30, 2023. These questions costs were for grants to students who lived in surrounding counties outside of West Virginia who were given waivers for the tuition above the University?s in-state rate, to student athletes and those with certain levels of academic achievement. In addition to the grants noted above, BSU used the Student Portion of HEERF funds to provide emergency funds to all students, based only on their part-time or full-time status. BSU relied on FAQ #s 11, 12 and 13 in determining that expending the funds was within the proper guidelines. For example, the funds were used for the students? cost of attendance and electronic or written authorization were received to use the funds to satisfy students? account balances. Nearly half of those who received the grants in question were Pell eligible (277 out of 600, or 46%). Similarly, approximately 46.9% of the funds spend on grants in these three categories went to Pell eligible students. Therefore, BSU believes that students with exceptional need were appropriately prioritized in awarding these grants. Out-of-state students faced an added financial burden based on the added cost of out of state tuition. Grants to those students to assist with that cost were not linked to any of the factors identified in the response to FAQ #12 as a basis for determining that an institution failed to prioritize emergency financial grants to students with exceptional need. Grants to out-of-state students were just one avenue of distributing HEERF funds to students, who were free to pursue other avenues of funding. As indicated above, BSU used the Student Portion of HEERF funds to provide emergency funds to all students, based only on part-time or full-time status, which given the high percentage of Pell eligible students attending BSU, reached many students with exceptional need. Due to the high proportion of Pell eligible students who received the grants in question and the high costs faced by the out-of-state students, BSU believes that the grants to out-of-state students did not demonstrate a failure to prioritize students with exceptional need. With respect to students who received grants who participated in athletic programs or demonstrated certain levels of academic performance, BSU notes again the group in question contained a high proportion of Pell eligible students. Funds were available through other means to students other than those participating in athletic programs or demonstrating high levels of academic performance (including but not limited to the out-of-state students discussed above or the emergency funds made available to all students based only on full-time or part-time status that were provided using the Student Portion of HEERF funds). Academic performance or athletic participation were not a prerequisite to receiving any assistance at all, but rather two ways to access assistance. Viewing efforts to provide aid to students as a whole, BSU does not believe that the distribution of HEERF funds demonstrated a failure to prioritize emergency financial aid grants to students with exceptional need. Glenville State University (GSU) response To ensure compliance with all federal reporting guidelines, existing federal time and effort calculation guidelines, along with relevant internal control policies and procedures, will be saved to a shared drive or other location to which the necessary personnel have access. As a best practice, primary consideration will be given for the usage of detailed time sheets or time logs being kept for each GSU employee whose time or effort is partially or wholly allocated to federal grant-related activity. These time sheets/time logs will include the percentage of time spent working on grant-related activities, the percentage of time spent working on non-grant university-related activities, a general description of activities performed for the grant related activity, and the total number of hours worked each week. Time sheets/logs will be reviewed and approved regularly by the grant-funded employee, the employee?s supervisor, and the Grants Compliance Director or designee. In cases for which the time sheet method is not deemed practical to be employed, the Chief Financial Officer or designee will draft a memo that provides a detailed explanation and justification of the method used for calculating time and effort. This memo will be signed by the Chief Financial Officer and the Director of Grants Compliance. On a quarterly basis, the Controller or Chief Financial Officer and Director of Grants Compliance will meet to ensure the relevant documented time and effort matches the corresponding draw down amounts. Mountwest Community and Technical College (MCTC) response Effective February 2022, MCTC enhanced policies and procedures to ensure formal approval and documentation of expenditures for HEERF funds is retained to ensure compliance.

View Audit 40967 Questioned Costs: $1

Finding 46290 (2022-022)

Material Weakness 2022

State of West Virginia

WV

Student Financial Aid Reporting Matching / Level of Effort / Earmarking § 200.303

REPORTING Fairmont State University, West Virginia State University, Bluefield State University, West Virginia Northern Community College, West Liberty University, Southern West Virginia Community and Technical College, Pierpont Community and Technical College, Concord University, Mountwest Communit...

REPORTING Fairmont State University, West Virginia State University, Bluefield State University, West Virginia Northern Community College, West Liberty University, Southern West Virginia Community and Technical College, Pierpont Community and Technical College, Concord University, Mountwest Community and Technical College, and Glenville State University Assistance Listing Number 84.425E, 84.425F, 84.425J, 84.425M Fairmont State University (FSU) response In regard to the Annual Reporting of HEERF, the Controller will work with the Financial Reporting Manager to ensure the annual data is accurate and reflects the data reported on the quarterly reporting for the same period. The Controller will perform data entry of all required fields in the annual submission website. Once complete, an email will be sent to the CFO for final review and approval. The CFO will provide email correspondence that the review is complete and the reporting is approved for submission. The CFO will submit the annual report via the reporting website. This action was implemented January 2023. West Virginia State University (WVSU) response WVSU developed and documented an internal control procedure to ensure compliance of HEERF Reporting. This procedure includes a dual review and sign off process by Business and Finance before the report is posted to WVSU?s website. This review includes ensuring accurate forms are being used for reporting. Additionally, screen captures are saved to provide a date/timestamp of when the report was made public. The control was implemented on or before July 1, 2022. Bluefield State University (BSU) response BSU has strengthened internal controls over reporting of HEERF funds to assure that the posting to the University website in a timely manner is documented in writing. BSU posted all reports to the University website on or before the filing deadline. However, we did not receive written documentation from our IT department to document the timely posting. We have revised our internal control procedures to ensure that that we receive and retain documentation of the posting date. BSU inadvertently used incorrect terminology to describe some of the emergency grants to students made from the Student Portion of HEERF funds. The reports selected for testing were for the Student Portion of funds that was reported in a narrative format. The revised reporting form issued by the Department of Education combines the reporting of Student, Institutional and HBCU funds on one standard form. This will eliminate these types of errors in subsequent reporting. West Virginia Northern Community and Technical College (WVNCC) response WVNCC is aware to include the total amount of grants distributed, the estimation of students to receive a grant and the total amount of students to receive the grant from the calculations used to issue Emergency Financial Aid Grants. In addition to reporting the method used to determine award amounts to students prior to the awards being disbursed, WVNCC will also include the method used in future reporting. As an added layer of review, WVNCC will include a third report reviewer from Student Accounts to verify the number and dollar amount of awards disbursed to be included in the report. This action was implemented in January 2023. West Liberty University (WLU) response As of January 2023, federal drawdowns are reconciled and reviewed prior to the drawdown. The signature of the Controller or CFO is on each drawdown with the date of review and approval. The drawdown is then completed usually on the same date as the review and approval. Southern West Virginia Community and Technical College (SWVCC) response SWVCC has enhanced its procedures surrounding the preparing, updating, and reviewing of quarterly and annual reports for the HEERF Education Stabilization Fund (and all other federal awards). The information utilized to prepare the reports is now dated and saved for future reference. The individual compiling the report documents the date the report is completed and submits it to the reviewer. The reviewer documents the date of review and any adjustments made to the report. The review is completed before the report is posted to the institution?s website and all documentation will be maintained for audit review. These procedures are in place as of January 2023. Pierpont Community and Technical College (PCTC) response PCTC?s staff and administration have reviewed the reporting requirements for HEERF funding to ensure quarterly and annual reports are accurate and timely. All staff involved in the reporting process, which includes the offices of Financial Aid, Registrar and Finance, have been directed to document and retain all source data used in the reporting process. A documented review process was put in place in October 2022 to ensure review by a supervisor and a final review by the Vice President of Finance and Administration/Chief Financial Officer or the Comptroller. Evidence of the review process is demonstrated through sign offs and/or e-mail communications. Concord University (CU) response Beginning with the December 2022 quarterly reporting, the coordination and approval of all reports will continue to be documented electronically. Additionally, the level of review/approval for the generated reports prior to posting will also be documented, and all work orders requesting the public posting of approved reports will include a cited reminder of the federal posting deadline for grant compliance. This additional information in the requested work order will ensure all parties involved are aware of and meet the required posting deadline. These steps were taken for the December 2022 Institutional Portion (CFDA #84.425F) quarterly reporting and resulted in a timely posting. The Student Aid Portion (CFDA #84.425E) final reporting occurred during fiscal year 2022. Mountwest Community and Technical College (MCTC) response For student reporting ? Q4 FY2021 and Q3 FY2022 there were no student reports prepared for these quarters. MCTC submitted OMB Control Number 1840-0849 with no expenditures reflected for HEERF I, II, or III Student Portion for FY21 Quarter 4 and FY 22 Quarter 3. All funds were fully expended by the end of FY 22 Quarter 2. Although there were no HEERF Student Portion funds expensed during the Quarters in question, MCTC has acknowledged that the language on the website should have been updated to disclose all funding as awarded and final. As a response to the finding, MCTC will develop a Quarterly Reporting schedule for posting on the website to capture all awarding activity from HEERF I, II, and III from point of initial receipt of HEERF funds through the grant end period, June 30, 2023. For Institutional Reporting ? Q4 FY2021 institutional report was not posted timely within the 10-day reporting requirement. This occurred before the PY corrective action plan was implemented. A corrective action plan was submitted on February 17, 2022 and all subsequent quarterly reports have been submitted timely. Glenville State University (GSU) response GSU implemented and strengthened internal controls surrounding the reporting for both HEERF II and III in February 2022. GSU has created and filled the position of Director of Grants Compliance. This new Director has direct oversight and assurance of GSU?s compliance with all grant reporting requirements. The Director will prepare and maintain a ?Master? checklist for all grants received by GSU. The checklist will be monitored and updated as reporting or compliance steps are met by the Director. The Director will coordinate with the relevant personnel with reporting or compliance responsibility over the grant to ensure the compliance expectations are met timely.

View Audit 40967

Finding 46287 (2022-025)

Significant Deficiency 2022

State of West Virginia

WV

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303

TRANSPARENCY ACT REPORTING Department of Education (DOE) Assistance Listing Number 84.425C, 84.425D, 84.425R, 84.425U Program management will implement policies and procedures to ensure that Transparency Act Reporting is conducted with proper reviews. In order to comply with the Federal Funding Acc...

TRANSPARENCY ACT REPORTING Department of Education (DOE) Assistance Listing Number 84.425C, 84.425D, 84.425R, 84.425U Program management will implement policies and procedures to ensure that Transparency Act Reporting is conducted with proper reviews. In order to comply with the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) (Transparency Act), as amended by Section 6202(a) of the Government Funding Transparency Act of 2008 (Pub. L. No. 111-252), that relate to sub-award reporting, the DOE Office of Internal Operations will work with each awarding office to ensure the sub-awards have been thoroughly reviewed and signed before reporting each month. This will comply with 2 CFR 200.303 which requires an entity to "maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award". The timeline for the development and initiation of this process (barring any unforeseen system limitations) is tentatively set for July 1, 2023.

View Audit 40967

Finding 46286 (2022-021)

Material Weakness 2022

State of West Virginia

WV

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

MAINTENANCE OF EFFORT Department of Education (DOE) Assistance Listing Number 84.425C/84.425D/84.425R/84.425U DOE submitted a waiver request in June 2022 and is currently working with the U.S. Education Department to obtain a waiver for Maintenance of Effort for FY22. DOE is also working with the ...

MAINTENANCE OF EFFORT Department of Education (DOE) Assistance Listing Number 84.425C/84.425D/84.425R/84.425U DOE submitted a waiver request in June 2022 and is currently working with the U.S. Education Department to obtain a waiver for Maintenance of Effort for FY22. DOE is also working with the Office of the Governor and Legislative Leaders to review compliance for the 2023 fiscal year.

View Audit 40967

Finding 46261 (2022-020)

Significant Deficiency 2022

State of West Virginia

WV

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.302 § 200.303 § 200.328 § 200.329

REPORTING West Virginia Division of Rehabilitation Services (WVDRS) Assistance Listing Number 84.126 WVDRS will review current RSA-17 approval procedures by April 2023 and make appropriate modifications as necessary to ensure all evidence of report approval is maintained within our records.

View Audit 40967

Finding 46260 (2022-019)

Significant Deficiency 2022

State of West Virginia

WV

Cash Management Matching / Level of Effort / Earmarking § 200.303

CASH MANAGEMENT West Virginia Division of Rehabilitation Services (WVDRS) Assistance Listing Number 84.126 WVDRS will review current cash approval procedures by April 2023 and make appropriate modifications as necessary to ensure all evidence of cash draw approval is maintained within our records.

View Audit 40967

Finding 46235 (2022-018)

Significant Deficiency 2022

State of West Virginia

WV

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

SPECIAL TESTS AND PROVISIONS ? DISBURSEMENTS TO OR ON BEHALF OF STUDENTS Pierpont Community and Technical College (PCTC) Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 84.408, 93.264, 93.342, 93.364, 93.925 PCTC?s standard procedure for disbursement letters is to have the...

SPECIAL TESTS AND PROVISIONS ? DISBURSEMENTS TO OR ON BEHALF OF STUDENTS Pierpont Community and Technical College (PCTC) Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 84.408, 93.264, 93.342, 93.364, 93.925 PCTC?s standard procedure for disbursement letters is to have the Information Systems Specialist (ISS) provide letters for review to the Director of Financial Aid before mailing. This was either not done by the ISS or overlooked by the Director. The process has been reviewed and communicated to the current Information Systems Specialist as well as the Assistant Director of Financial Aid. The Assistant Director of Financial Aid is authorized to review letters in the absence of or instead of the Director. This action was implemented January 2023.

View Audit 40967 Questioned Costs: $1

Finding 46234 (2022-017)

Significant Deficiency 2022

State of West Virginia

WV

Special Tests & Provisions Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

SPECIAL TESTS AND PROVISIONS ? GRAMM-LEACH-BLILEY ACT ? STUDENT INFORMATION SECURITY Fairmont State University and Pierpont Community and Technical College Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 84.408, 93.264, 93.342, 93.364, 93.925 Fairmont State University (FSU...

SPECIAL TESTS AND PROVISIONS ? GRAMM-LEACH-BLILEY ACT ? STUDENT INFORMATION SECURITY Fairmont State University and Pierpont Community and Technical College Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 84.408, 93.264, 93.342, 93.364, 93.925 Fairmont State University (FSU) response FSU entered into a contract with Wolf & Company to perform an external risk assessment for our systems in 2021 but was not completed due to staffing changes until 2022. The external risk assessment was received from Wolf in June 2022. The report and its suggestions were immediately reviewed and approved. This action will be implemented in January 2023 for fiscal year 2023 and will be implemented each July, starting with July 2023, hereafter. It was not understood that annual reviews needed to occur at the beginning of each fiscal year until this finding was received. Pierpont Community and Technical College (PCTC) response In December 2022 and January 2023, PTCT developed the following policies and procedures, which also detail internal controls, relative to the Gramm-Leach-Bliley Act and student information security. ? Access to Security Controlled Spaces Policy ? Anti-Virus Policy ? Backup and Recovery Policy ? Change Management Policy ? Computer Disposal Policy ? Computer Security Policy ? Data Security Policy ? IT Firewall Policy ? IT Incident Response Policy ? System Update Policy ? Mobile Device Use Policy ? Remote Access Policy ? Risk Assessment Policy ? Banner Document Procedure ? Banner Security Procedure ? Argos Access Procedure ? Active Directory Security and User Creation ? National Student Loan Clearinghouse Enrollment Submission Procedure ? National Student Loan Clearinghouse Graduate Only Submission Procedure ? Nelnet Refunds Procedure ? Risk Assessment Procedure Risk assessments will now be performed two times a year and will follow the Risk Assessment Procedure. This procedure also incorporates all policies, procedures, and internal controls as the framework for the ensuring of student information security.

View Audit 40967

Finding 46233 (2022-016)

Significant Deficiency 2022

State of West Virginia

WV

Matching / Level of Effort / Earmarking Special Tests & Provisions Student Financial Aid § 200.303

SPECIAL TESTS AND PROVISIONS ? BORROWER DATA TRANSMISSION AND RECONCILIATION Pierpont Community and Technical College and West Virginia State University Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 84.408, 93.264, 93.342, 93.364, 93.925 Pierpont Community and Technical ...

SPECIAL TESTS AND PROVISIONS ? BORROWER DATA TRANSMISSION AND RECONCILIATION Pierpont Community and Technical College and West Virginia State University Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 84.408, 93.264, 93.342, 93.364, 93.925 Pierpont Community and Technical College (PCTC) response Beginning July 1, 2022, PCTC has updated the monthly reconciliation process. The Direct Loan School Account Statement (DLSAS) reports from Common Origination and Disbursement (COD) are downloaded by the 10th of each month, as before, by the Information Systems Specialist (ISS). The reports are now provided to the Assistant Director of Financial Aid (Asst.) and then reconciled to both Banner paid and COD approved Direct Loan disbursements. Reports verifying reconciliation are then completed and saved by the Assistant Director of Financial Aid and reviewed by the Director of Financial Aid for completion and accuracy. PCTC will maintain the documentation of the DLSAS statements each month and the reconciliation report along with evidence of said review. West Virginia State University (WVSU) response After each weekly disbursement, the Financial Aid Technician requests a Year-to-Date SAS Disbursement Detail on Demand Report from COD. The report is compared with the disbursement data within Banner and a COD/Banner Comparison Report is generated. The comparison report is sent to the Associate Director of Financial Aid and Director of Financial Aid to correct and document any discrepancies and if necessary, refers to the monthly DLSAS reports to verify resolution to any found discrepancies. The monthly DLSAS report is reviewed each month by the Director of Financial Aid to confirm consistency between fund disbursement and drawdownsreturn of payments by the Fiscal Office. The Director of Financial Aid and Business and Operations Manager both sign off weekly confirming accuracy. Effective August 2022, policies and procedures have been updated so any corrections applied will be documented, dated and saved by the Associate Director of Financial Aid and/or Director of Financial Aid.

View Audit 40967

Finding 46232 (2022-015)

Material Weakness 2022

State of West Virginia

WV

Questioned Costs Special Tests & Provisions Matching / Level of Effort / Earmarking § 200.303

SPECIAL TESTS AND PROVISIONS - VERIFICATION Bluefield State University, Fairmont State University, and Pierpont Community and Technical College Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 84.408, 93.264, 93.342, 93.364, 93.925 Bluefield State University (BSU) response...

SPECIAL TESTS AND PROVISIONS - VERIFICATION Bluefield State University, Fairmont State University, and Pierpont Community and Technical College Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 84.408, 93.264, 93.342, 93.364, 93.925 Bluefield State University (BSU) response Effective January 2023, after all calculations are made and checklists are completed the files will be reviewed by another counselor for accuracy. This reviewer will sign off on the file and checklist that it has been reviewed and no errors were found or recalculation needed. Both the preparer and the reviewer will sign off and date the checklist. Fairmont State University (FSU) response Controls were put into place in 2020-2021 to address the additional review of the verification process once the initial review was completed. FSU found that through some reporting and timing that the additional review did not occur for all students. FSU will implement a weekly review with a comprehensive review monthly to ensure no students are missed through the additional review process in February 2023. Pierpont Community and Technical College (PCTC) response Staff members have been, and will continue to be, prompted to print, scan and keep all documentation pertaining to verifications. In these two cases, the counselor did not print the Confirmation page that displays upon completing V4 & V5 verifications in Central Processing System (CPS) and did not follow the flow of placing the verification packet in the appropriate location for second review. PCTC has reviewed policies and procedures and made a slight modification. Beginning with the 22/23 aid year, the Financial Aid Administrator (FAA) brings the completed verification packet to the Director of Financial Aid. The Director then determines who will complete the second review. The second review can be completed by either the Director of Financial Aid, the Assistant Director of Financial Aid or another qualified FAA. Once completed and signed off, the verification packet is place into the permanent individual student?s file.

View Audit 40967 Questioned Costs: $1

Corrective Action Plans

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